I echo what Pete Reinhardt recommended. It would be helpful to understand the background of the person making the request. The EPA recently collected comments on its proposed changes to RCRA rules regarding hazardous waste, and these changes will affect colleges and universities. If this is someone who is working on that Generator Rule, then I recommend that he speak with representatives from DCHAS, CSHEMA and others. CSHEMA has reached out to EPA to suggest such a conversation. The people working on the new generator rules include individuals who are well aware of college and university issues, having worked with several of us before issuing Subpart K.

Chapter 11 of the 2011 edition ofPrudent Practices in the Laboratory (National Academies Press) has a thorough discussion of regulations and standards that apply to laboratories. Another good reference is the 2008 edition of theEnvironmental Compliance Guide for Colleges and Universities, published by APPA and CSHEMA. Also, the ACS Task Force on Laboratory Chemical and Waste Management publishedLaboratory Waste Management: A Guidebook. The second edition is published by Oxford Press.

All, I recently had a conversation with a colleague from EPA concerning hazardous waste compliance for universities, and in our conversation I offered to post an email from him on this list-serve to tap into its collective knowledge (see his email below).

"I am in the process of developing a hazardous waste compliance assistance program for colleges and universities (truly any post-secondary learning institution). Congress asked us [EPA] to regulate the management of hazardous waste through the Resource Conservation and Recovery Act (RCRA). We've routinely done inspections and regrettably find that universities tend to have numerous challenges with waste identification and management. I'm hoping your professional experience in both investigations and education (both as an educator and for the American Chemical Society) can help me find a more effective path than what we have pursued in the past."

So, ideas anyone?

One thing that struck me during the conversation was an article that I saw printed in JCHAS I think in 2010 that listed the numerous federal/state regulations a university was subject to. I remember being surprised by the number of requirements, and thought it would be insightful for this person as well. Despite searching my paper copies of JXHAS and JCHAS' search engine, I'm coming up empty. Any chance someone remembers an article like that?

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